Round 3-1a: Establish National Remedy Review Board
This reform established the National Remedy Review Board (the Board), in January 1996, to review and analyze proposed site-specific cleanup strategies. The goals of the Board are:
- Improve national consistency in Superfund remedy selection;
- Improve remedy cost-effectiveness;
- Confirm that decision-making at high cost sites is technically sound; and
- Ensure that decisions are in accordance with current law, regulations, and guidance.
Implementation of this reform is complete.
The Board will continue to (1) review site cleanup decisions, (2) review non-time-critical removal actions that meet certain criteria, and (3) implement recommendations to refine the scope and nature of both the Board's mission and its implementation procedures.
The Board has undergone scrutiny by both private parties and Congress, and reaction to the Board's accomplishments to date is generally positive.
- As of FY01, the Board had reviewed a total of 59 cleanup decisions with estimated savings of over $80 million.
- Regions have observed a wide range of additional benefits from the review process, including improved national consistency, clarity of decisions, and cross-Regional communication on key remedy selection issues.
- In FY97, the Board conducted an in-depth analysis of its operating procedures, and revised several key protocols based on analysis of feedback from concerned stakeholders. Of particular note, the Board raised the limit on technical submissions from stakeholders from five to ten pages, and instituted procedures to review high cost non-time-critical removal actions.
A December 1996 report by the Superfund Settlements Project, "EPA's Superfund Reforms: A Report on the First Year of Implementation," stated:
"The new National Remedy Review Board is widely regarded as the flagship among the 20 reforms announced on October 2, 1995."
Anaconda Smelter Site, MT
The Anaconda Smelter site covers 5,000 acres in Anaconda, Montana. A smelting operation operated on site from the late 1800s until it closed in September 1980, contaminating much of the area with heavy metals and other dangerous substances.
A key part of EPA's cleanup plan is to use revegetation to prevent contamination from spreading, and to protect the public and ecosystem from the site contamination. The NRRB reviewed the proposed cleanup decision for the Anaconda Smelter Superfund site in March and April of 1997. The Board offered several recommendations for the Region to consider as they finalized their cleanup plans.
EPA Region 8 responded with a proactive, creative approach to dealing with board concerns. Among the actions Region 8 took was to devise an inventive decision-making system that helped them focus their revegetation efforts. To develop the system, the Region took into account a vast amount of data gathered at the site and during the public comment period on the proposed cleanup. In cooperation with those responsible for cleaning up the contamination, as well as the State of Montana and community stakeholders, the Region is using its system to assess physical and chemical data and vary the site revegetation levels.
Thus, they are able to improve the cost effectiveness of their cleanup without sacrificing the level of protection it provides. These efforts, in part, enabled the Region to revise their cost estimate for the site from approximately $180 million to an estimated range of $90 million to $160 million. [FY98 Success]
New Bedford Harbor Site, MA
Since the Board's FY96 annual report, several Regions have reported significant benefits from the Board's reviews. For example, the Board reviewed a cleanup decision for the New Bedford Harbor site in Massachusetts. One of the Board's recommendations was for the Region to assess whether their air monitoring program was overly extensive, given the nature of the contaminants and actions planned at the site. The Region subsequently reassessed the need for continued monitoring of this nature. In so doing, the Region made adjustments in the monitoring program, reducing the costs by approximately $8.4 million. [FY97 Success]
Title: National Remedy Review Board Memorandum and Fact Sheet
Date: September 26, 1996
Synopsis: These documents provide background on the Board and describe the Board's key operating protocol. They were published as attachments to the FY96 Progress Report (see below).
Title: National Remedy Review Board Progress Report: Fiscal Year 1996
Date: January 1997
Document #: EPA 540-R-97-001, OSWER 9220.0-24, NTIS PB97-963201
Synopsis: This report highlights the accomplishments of the Board in its first year of operation. It is also i ntended to provide general information on the Board and how it o perates.
Title: National Remedy Review Board Progress Report: Fiscal Year 1997
Date: February 1998
Document #: EPA 540-R-97-032, OSWER 9220.0-26, NTIS PB98-963250
Synopsis: This publication is the National Remedy Review Board's second annual report. It presents the activities and accomplishments of the Board in fiscal year 1997.